Workplace Harassment Prevention Plan Template — Newfoundland and Labrador

Published by: Canada Policy Manual
Jurisdiction: Newfoundland and Labrador
Last updated: August 13, 2026
Document status: Published public template — approved for publication by Canada Policy Manual on August 13, 2026
Canonical page: https://canadapolicymanual.com/free-policies/workplace-harassment-policy/newfoundland-and-labrador

Important use notice

This is a rigorous drafting template, not legal advice or a promise of legal immunity. The governing jurisdiction depends on the workplace and undertaking; federally regulated status depends primarily on the undertaking, not simply the employee's physical location. Laws, regulator interpretations and sector-specific rules may change after the last-updated date.

Before an employer issues or relies on this policy, it must:

1. confirm that this is the correct jurisdiction and check all sector-specific requirements;
2. replace every square-bracketed field and delete all drafting notes;
3. complete all legally required consultation, joint development, assessment, posting, availability and training steps;
4. insert workplace-specific hazards, controls, reporting recipients, emergency contacts and support services;
5. reconcile the policy with collective agreements, contracts, privacy, human rights, accessibility, professional, child/vulnerable-person, whistleblower and other applicable rules;
6. obtain qualified jurisdiction-specific legal advice for its operations and workforce; and
7. keep evidence of approval, communication, training, investigation, corrective action and every required review.

Legal requirement identifies a rule expressly reflected in cited occupational health and safety legislation. Regulator-stated expectation or adopted code method identifies official guidance or an approved code method. Enhanced control identifies a stronger administrative practice and is not represented as a statutory rule unless the policy expressly says otherwise.

Quebec is intentionally excluded. Do not use this template for a Quebec workplace.

Workplace Harassment Prevention Plan

1. Plan record

This written plan was developed, implemented and is maintained in consultation with [applicable body]. It is accessible to all workers.

2. Commitment and scope

Every worker has the right to work free from harassment. [Employer] will eliminate or, where elimination is not possible, minimize workplace-harassment risk; investigate complaints; protect workers from retaliation; support affected workers; and correct conduct and systemic hazards. Workers must not bully or harass, must report harassment they observe or experience, must comply with this plan and must cooperate with investigations. Supervisors must ensure those duties are followed and act on known risk.

The plan covers workers, supervisors, managers, owners, directors, contractors, volunteers and work-related third parties and applies to connected conduct in physical/remote work, travel, training, employer lodging, events, client sites, vehicles and digital communications.

3. Definitions

Under the OHS Regulations, workplace harassment means inappropriate vexatious conduct or comment by a person to a worker that the person knew or ought to have known would cause the worker to be humiliated, offended or intimidated. Reasonable action by an employer or supervisor relating to management and direction is excluded. The policy additionally prohibits discriminatory and sexual harassment, bullying, poisoned-environment conduct and other serious disrespect that may be broader than the statutory test.

Examples include threats, abuse, degrading/discriminatory comments or displays, malicious gossip, cyber-harassment, hazing, stalking, repeated isolation, sabotage, sexualized messages/jokes/contact, unwanted advances, sexual coercion/benefit, and retaliation. Reasonable feedback, assignment, scheduling, investigation, discipline or organizational change is not harassment when lawfully and respectfully carried out.

4. Risk assessment and controls

The violence risk assessment required by s. 22.1 and the harassment-prevention process will consider prior experience, similar operations, work location and circumstances, worker demographics and culture, new/young workers, committee/representative concerns, public/client interaction, lone work, travel, digital systems, power imbalance and family violence. Identifying information is protected. Schedule NL-1 records hazards, existing controls, residual risk, additional measures, owners and dates.

Controls can include staffing, check-ins, access/security, duress communications, public/client rules, contract clauses, role/workload clarity, platform controls, de-escalation and respectful-supervision measures. Workplace violence and family violence are also governed by ss. 22.1–24 and [companion violence plan]. In immediate danger, move to safety, call 911/local emergency services, use [security] and obtain first aid/medical care.

5. Reporting and response

Report orally or in writing to [employer/supervisor recipient]. If the employer or supervisor is alleged, report to [external third-party recipient], as the Regulations require the plan to provide. A witness, representative or third party may report. Managers must escalate knowledge; no formal complaint, confrontation or informal step is a prerequisite.

State names, words/actions, dates/locations/frequency, witnesses, documents/messages, impact and immediate needs if known. A form is optional. Anonymous, late or incomplete information is assessed fairly.

Enhanced target: acknowledge within 2 business days, immediately screen safety/violence, conflict, reprisal, accessibility/accommodation and evidence needs, explain process/privacy/representation/external rights, preserve records and offer support. Interim no-contact, security, reporting/schedule/location change, paid leave, remote work or reassignment must be neutral, proportionate, reviewed every 30 days and not punish the reporting worker.

6. Investigation and resolution

[Employer] will investigate every complaint. A voluntary informal approach may resolve suitable low-level conduct but is never mandatory and is generally excluded for serious sexual/discriminatory conduct, violence, coercion, retaliation or material power imbalance. Withdrawal does not automatically end action where safety or legal duties remain.

An impartial competent investigator uses written terms of reference; identifies allegations/tests; notifies parties; permits appropriate representation/support; interviews separately; gathers relevant evidence; gives the respondent adequate particulars and response opportunity; lets parties address material conflicting evidence; assesses credibility neutrally; and makes balance-of-probabilities findings. Enhanced target: 90 calendar days; if longer, reasons are documented and monthly updates provided.

The investigator reports process, facts, findings, reasoning and corrective recommendations. An OHS officer may order an impartial third party to investigate at the employer's expense. The employer will not interfere with that process.

As [Employer]'s procedure under s. 24.1(2)(h), both the complainant and responding person receive a written summary of results and action relevant to them, subject to privacy. Writing and notice to both parties are stronger internal standards; the Regulation requires the plan to state its notification procedures but does not itself prescribe those two details. Corrective action may include direction, education, coaching, monitoring, work redesign, accommodation, security/contract controls, reassignment, discipline up to termination and third-party exclusion. Follow-up at 30, 90 and 180 days verifies implementation and reprisal protection.

7. Privacy, retaliation, records, training and review

Names/circumstances are disclosed only as necessary to investigate, correct, inform parties of results/action or comply with law. Participants may access a representative, support, medical/legal advice, regulator or police and make protected reports. Retaliation, threat, adverse treatment, ostracism or witness/evidence interference is prohibited and separately investigated. An unproven complaint is not bad faith.

Case records are role-restricted and separate from ordinary personnel files. Enhanced retention: 7 years after closure; plan/consultation/risk assessment/training/review records for the active life plus 7 years, subject to longer legal hold.

The employer participates in harassment-prevention training and provides training to employees. Training covers definitions, recognition, reporting routes, investigation, privacy, support, bystander action, supervisor duties and reprisal, with records of content, attendance and competency. The plan is reviewed as necessary and at least annually. [Employer] adopts consultation with the applicable body on each review and records it as a stronger internal standard; s. 24.1 expressly requires consultation in developing, implementing and maintaining the plan, but does not separately repeat consultation in the annual-review clause. Changes trigger communication and retraining.

The plan does not discourage rights under the Human Rights Act, 2010, Criminal Code or other law, or access to the Department of Government Services, Occupational Health and Safety Division, WorkplaceNL, police, a union/arbitrator, privacy regulator or court/tribunal. Effective June 1, 2026, WorkplaceNL Policy EN-18 addresses diagnosed psychological injuries arising from workplace harassment.

Newfoundland and Labrador authoritative sources

• Occupational Health and Safety Regulations, 2012 — ss. 22.1 to 24.2
• WorkplaceNL OHS Guide — Violence and harassment
• WorkplaceNL — Policy update on psychological injuries arising from workplace harassment (effective June 1, 2026)
• Newfoundland and Labrador Government Services — Occupational Health and Safety Division
• Human Rights Act, 2010

Operational schedules and forms

These schedules form part of this Newfoundland and Labrador policy unless governing law requires a different process. They have been separated and specialized for this jurisdiction. A jurisdiction-specific rule overrides a generic target. Do not issue blank schedules as if they were completed controls.

Mandatory Newfoundland and Labrador schedule preset

Insert this policy's express consultation, posting/availability, investigation, notice, training, review and companion-violence rules; never replace them with generic 90-day, annual or 7-year enhanced defaults.

Schedule A — Pre-issue implementation certificate

The accountable officer and implementation lead must initial each item and attach evidence.

Certification: We have not treated publication as implementation. Based on the attached evidence, the selected policy is customized, consulted on, communicated, trained and operational at the workplaces listed.
Senior officer: [Name/signature/date]
Implementation lead: [Name/signature/date]
Required workplace party acknowledgement: [Name/role/signature/date; acknowledgement is not a waiver of disagreement]

Schedule B — Workplace harassment and violence hazard assessment

Complete separately for each materially different workplace, work group or remote/camp setting. A check mark alone is not an assessment; document evidence, people consulted and control effectiveness.

B1. Assessment metadata

B2. Risk inventory and action plan

Rate likelihood and consequence using the employer's approved risk matrix. Psychological, sexual and discriminatory harm must not be discounted because no physical injury occurred.

B3. Control hierarchy and sign-off

For every high or critical risk, document why elimination is not reasonably practicable before relying only on policy or training. Consider elimination/substitution of the triggering activity; engineering/physical/digital controls; staffing/work-design/administrative controls; training/supervision; and emergency/support measures. Identify residual risk communicated to workers and the minimum necessary threat information.

Approved controls and funding: [ ]
Unresolved joint/consultation issues and governing resolution process: [ ]
Next review date or earlier triggers: [ ]
Signatures/decision record: [ ]

Schedule C — Report / notice of occurrence form

Use of this form is optional unless law requires particular information. Accept oral, accessible-language, representative-assisted and alternative-format reports.

C1. Reporter and people involved

• Reporter name/contact (optional for a witness where law permits anonymous notice): [ ]
• Person allegedly affected / preferred safe contact: [ ]
• Person(s) whose conduct is at issue / role / employer, if known: [ ]
• Witnesses or people with relevant information: [ ]
• Representative, interpreter, support or accommodation requested: [ ]
• Is any normal reporting recipient involved or conflicted? [Yes/no/details]

C2. Occurrence

• Date(s), time(s), physical/virtual location(s) and platform(s): [ ]
• Exact words, actions, displays, messages, gestures, contact or threats, in chronological order: [ ]
• Why the conduct was unwelcome or its health/safety/work impact: [ ]
• Related protected characteristic, sexual conduct, violence or domestic/family violence concern, if the reporter chooses to identify it: [ ]
• Was anyone told the conduct was unwelcome? [Optional; a “no” does not invalidate the report]
• Prior related occurrences/reports and response: [ ]

C3. Evidence, safety and outcome sought

• Emails, chats, images, audio/video, documents, access/security records, notes or other evidence and where preserved: [ ]
• Immediate or continuing danger; weapons; stalking; self-harm; medical/first-aid concern; contact with police/security: [ ]
• Reprisal, evidence-loss, conflict, privacy, housing/transport or immigration/precarity concern: [ ]
• Interim measure, support, accommodation or communication preference requested: [ ]
• Resolution preference, recognizing the employer may still have a duty to investigate/correct: [ ]

Accuracy: I believe the information is true and complete to the best of my knowledge. I understand the employer will share information only as necessary for safety, a fair process, corrective action or law and cannot promise absolute secrecy.
Signature / recorded oral confirmation / date: [ ]
Received by / date/time / channel / case number: [ ]

Schedule D — Recipient intake, safety and conflict checklist

Complete immediately and update whenever risk changes.

1. Jurisdiction and coverage: confirm governing law, workplace, worker status, former-worker rule and any sector-specific or collective-agreement process.
2. Emergency triage: imminent danger; medical/first aid; suicide/self-harm; sexual assault; child/vulnerable-person duty; weapon; stalking; domestic/family violence; police/security; serious-incident reporting; scene/evidence protection.
3. Conflict screen: recipient, investigator, decision-maker, counsel, representative, interpreter, senior leadership, family/community or reporting relationships. Record actual, potential and perceived conflicts and mitigation.
4. Acknowledgement: date due under law; actual date; policy/process/representation/external-right information provided; accessibility/language confirmed.
5. Evidence hold: identify custodians, platforms, auto-delete periods, CCTV/access retention, devices, notes, social media, work records and preservation owner. Preserve proportionately and lawfully; do not conduct overbroad surveillance.
6. Interim measures: risk addressed; party views considered; least prejudicial effective measure; pay/benefits/accommodation maintained; decision-maker/reasons; communication; 30-day review date.
7. Supports: EAP/medical/counselling/sexual-violence/community/culturally safe/union/legal/accommodation contacts offered without requiring a finding.
8. Process route: threshold review, required investigation, possible voluntary resolution, parallel criminal/regulatory/grievance process, privilege decision and statutory reporting.
9. Communications: safe channels, no-contact rules, status-update cadence, media/public-contact control where lawful, and no promise of exact discipline or absolute confidentiality.
10. Case plan: allegations/issues list, investigator/decision-maker, terms of reference, target dates, statutory deadline, review/report recipients and corrective-action owner.

Recipient signature/date: [ ]
Supervisor notification limited to need-to-know: [ ]
Next safety review: [ ]

Schedule E — Investigation terms of reference and mandatory protocol

E1. Appointment and independence

• Case number / appointing authority / governing policy and legislation: [ ]
• Investigator name, qualifications, role-specific legal/investigation training and secure contact: [ ]
• Written conflict declaration and continuing duty to disclose: [ ]
• Parties' input/selection process and any regulator order: [ ]
• Investigator decides facts and policy breach unless law/terms assign otherwise; employer decides discipline/corrective action.
• Legal privilege, if legitimately claimed, must be defined at the outset and not used to conceal a statutory report that must be disclosed.

E2. Allegations and scope

List each allegation separately: who; what; when/where; policy/statutory test; and whether retaliation, systemic failure, violence or protected-ground harassment is included. Scope changes require written reasons and notice sufficient for fairness. The investigator does not decide unrelated performance or credibility issues merely because they arise.

E3. Fair procedure

The investigator will:

1. provide each party a plain-language process explanation, allegations and a meaningful opportunity to participate;
2. arrange disability, trauma, language, cultural, scheduling and technology accommodations without compromising neutrality;
3. permit an appropriate union/other representative or support person, subject to non-interference and confidentiality;
4. interview separately, ask open and testing questions, obtain names/sources, and allow corrections to interview summaries;
5. collect relevant proportionate evidence and maintain an evidence log with source, date, authenticity and access history;
6. give the responding party sufficient particulars and a fair opportunity to answer;
7. put material adverse or contradictory evidence to the affected party before relying on it, while protecting safety and nonessential identity information;
8. assess relevance, reliability, consistency, plausibility, contemporaneous records, motive to misstate and corroboration without relying on myths about trauma, delayed reporting, disability, culture or demeanor;
9. apply the balance of probabilities unless governing law requires otherwise, decide each allegation separately and distinguish “not substantiated” from “false”; and
10. report facts, reasoning and recommendations within the governing deadline or documented enhanced target, with regular status updates.

No participant may secretly record an interview. The investigator may authorize recording with informed agreement, security controls and a retention plan. The employer will not require broad access to personal devices/accounts without lawful necessity and proportionality.

E4. Report structure

1. mandate, independence and legal/policy framework;
2. allegations and applicable tests;
3. procedure, participants, accommodation and limitations;
4. evidence considered and not obtained;
5. undisputed/material facts;
6. credibility and reliability analysis tied to evidence;
7. finding and reasons for each allegation;
8. retaliation, systemic risk and immediate safety findings;
9. corrective/preventive recommendations, owners or priorities where within mandate; and
10. appendices/evidence index, with redaction/version controls.

Target date / statutory final date / update cadence: [ ]
Required report copies and outcome notices: [ ]

Schedule F — Investigation quality and credibility worksheet

Do not use numerical scoring as a substitute for reasoning.

Quality checks:

• Were material contradictions put to the person affected?
• Were messages/records assessed in full context and authenticated sufficiently?
• Were trauma, disability, language, culture and power considered without stereotyping?
• Was demeanor given little or no weight unless specifically reliable and explained?
• Was each conclusion tied to evidence and the correct policy/legal definition at the time?
• Were intent and impact treated according to the applicable test?
• Were management-action exclusions examined for reasonableness, good faith and method?
• Were broader internal conduct standards kept distinct from statutory findings?
• Were exculpatory evidence and investigation limitations addressed?

Schedule G — Outcome notice templates

Adapt to the jurisdiction. Never use this template to disclose less than an express statutory outcome requirement.

G1. Notice to complainant / principal / allegedly affected worker

Private and confidential — Case [ ]
We investigated the report received on [date] concerning [brief neutral description]. The investigation was conducted by [role/name where appropriate] under [policy/law]. You had an opportunity to provide information and respond to material issues.

Result for each allegation: [substantiated / substantiated in part / not substantiated / unable to determine, only if policy/law permits, with the specific result description the jurisdiction requires]. [Concise reasons or findings summary required for a meaningful result notice, without unnecessary personal information.]

Corrective or preventive action taken or to be taken that may be disclosed: [specific measures relevant to the result; do not promise or reveal confidential discipline beyond what law requires]. The employer will monitor completion and retaliation. Report any concern to [channel]. Available supports/accommodations are [ ]. This notice does not restrict external legal rights listed in the policy.

G2. Notice to respondent / alleged harasser

Private and confidential — Case [ ]
Result for each allegation: [ ]. Corrective expectations/actions applicable to you: [ ]. Any discipline is communicated in a separate employment letter where appropriate. Retaliation, contact contrary to interim/final directions, and interference are prohibited. Questions about compliance go to [ ]. This notice does not restrict representation or legal rights.

G3. Closure acknowledgement

G4. Fixed reporting and outcome calendar

Schedule H — Corrective action and effectiveness tracker

Corrective action must address both individual conduct and enabling conditions. Possible indicators include repeat reports, affected-area climate, control use, training comprehension, turnover/absence themes, security events and completion audits. Do not measure success by “zero complaints” alone; under-reporting can produce that number.

Schedule I — Training standard and record

I1. Minimum curriculum

All-person training is workplace-specific and covers:

1. policy commitment, legal/internal definitions and reasonable-management boundary;
2. discriminatory, sexual, gender-based, personal, third-party and virtual harassment examples;
3. violence/domestic-family-violence overlap and emergency assistance;
4. workplace-specific hazards and controls;
5. reporting, alternate/independent channels, anonymous information and evidence preservation;
6. what happens after a report, interim measures, representation, investigation and outcomes;
7. confidentiality limits, lawful support/external reporting and prohibition on reprisal;
8. bystander options that do not require unsafe intervention;
9. accommodation, language, cultural and trauma-informed access; and
10. scenario practice and a documented comprehension check.

Supervisors/recipients receive additional training on duty to act without a formal complaint, emergency triage, domestic violence, conflict screening, intake, no promise of secrecy, neutral interim measures, evidence holds, procedural fairness, outcome communications, corrective action and record/reporting duties. Investigators meet the law-specific qualification rules.

I1A. Mandatory Newfoundland and Labrador training override

• Newfoundland and Labrador: use this policy's express training requirements and role coverage; do not substitute the generic curriculum for them.

I2. Record

Schedule J — Policy and program review record

Review trigger / legal deadline: [ ]
Participants and disagreements: [ ]
Approval / communication / retraining dates: [ ]
Next scheduled and event-triggered review rules: [ ]

Schedule K — Case record index and access protocol

Access is not granted merely because a person is a supervisor or executive. Every access/export is need-to-know, logged where practical, securely transmitted and limited to the minimum necessary. A privacy request, grievance, litigation hold, regulator order, police request or legal disclosure is routed to [privacy/legal lead]; no routine deletion occurs while a valid hold applies.

K1. Minimum Newfoundland and Labrador retention preset

Do not destroy records merely because a listed minimum expires. Apply the authorized disposition schedule, privacy minimization requirements and any litigation, grievance, regulator, workers' compensation or preservation hold.

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